Law on the Central Register of Beneficial Owners – new obligations starting October 1, 2025

From 1 October 2025, the new Law on the Central Register of Beneficial Owners (“Official Gazette of RS”, Nos. 19/2025, 51/2025, and 60/2025 – corrigendum) will enter into force, introducing significant changes in the registration of the ownership structure of legal entities and other registered subjects (“Law”).

The purpose of the Law is to enhance business transparency and improve the fight against money laundering and the financing of terrorism.

The Law expands the scope of entities required to register their beneficial owners in the Central Register of Beneficial Owners (“Central Register”). In addition to commercial companies (excluding public joint-stock companies), cooperatives, branches, institutions, foundations, endowments, and representative offices of foreign companies, the obligation now also applies to trusts and legal arrangements similar to trusts that are managed from the Republic of Serbia or conduct business with legal or natural persons in Serbia.

The Law also introduces an expanded scope of data that registered entities must record. In addition to basic identification data, entities are now required to provide the legal basis for determining the beneficial owner, the date of acquiring such status, the date of registration, and documentation confirming the basis of ownership.

The Business Registers Agency maintains and publishes on its website a list of registered entities that have failed to record their beneficial owners in the Central Register within the statutory deadline:

  • Newly registered entities – within 30 days of establishment or from the date of removal of the previous beneficial owner from the register;
  • Existing entities – those that, prior to the entry into force of the Law, have not recorded data on their beneficial owner, or those that have not submitted documentation establishing ownership within 60 days from the Law’s entry into force.

The Agency is required to update this list every 48 hours, and entities listed are considered high-risk under the Law on the Prevention of Money Laundering and the Financing of Terrorism.

Registered entities are now required to review the recorded data at least once a year and confirm its accuracy and up-to-dateness within 30 days thereafter.

However, the Law provides exemptions in cases where transparency is already ensured by the nature of the business. For example, entities in bankruptcy or under compulsory liquidation proceedings are exempt from identifying and recording the beneficial owner.

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